GO2-10-098, Request for Approval of the Cyber Security Plan

Request for Approval of the Cyber Security Plan

ML102150353
Person / Time
Site:	Columbia
Issue date:	07/22/2010
From:	Atkinson D Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-10-098, TAC ME2624
Download: ML102150353 (10)

Text

Dale K. Atkinson ENE G NERGYiESTaP.O. Vice President, Operational Support Box 968,PE0

-NORTRichland, WA 99352-0968 Ph. 509.377.4302 1F. 509.377.4098 dkatkinson @ energy-northwest.com July 22, 2010 G02-10-098 10 CFR 73.54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN

References:

1) Letter G02-09-153 dated November 16, 2009, DK Atkinson (Energy Northwest) to NRC, "Request for Approval of the Columbia Generating Station Cyber Security Plan"

2) NRC Letter dated May 24, 2010, CF Lyon (NRC) to JV Parrish (Energy Northwest), "Columbia Generating Station - License Amendment Request for Approval of the Cyber Security Plan (TAC No. ME2624)"

3) NEI 08-09 Revision 6, "Cyber Security Plan for Nuclear Power Reactors,"

April 2010

4) NRC Letter dated June 7, 2010, RP Correia (NRC) to CE Earls (NEI),

"Nuclear Energy Institute 08-09, 'Cyber Security Plan Template, Rev. 6"'

Dear Sir or Madam:

As requested in Reference 2, Energy Northwest hereby withdraws the Reference 1 Cyber Security Plan application and submits a revised Cyber Security Plan application based on Reference 3 with a Reference 4 definition for cyber attack.

In accordance with the provisions of Section §73.54 Title 10 of the Code of Federal Regulations (10 CFR) and Reference 2, Energy Northwest is submitting, as specified in

§50.4 and §50.90, a request for an amendment to the Facility Operating License (FOL) for Columbia Generating Station (CGS). This proposed amendment requests Nuclear Regulatory Commission (NRC) approval of the CGS Cyber Security Plan, provides an Implementation Schedule, and proposes a revision to the existing FOL Physical Protection license condition 2.E to require Energy Northwest to fully implement and maintain in effect all provisions of the Commission approved CGS Cyber Security Plan.

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 2 provides an evaluation of the proposed change and contains the following attachments:

" Attachment 1 provides a marked-up page showing the proposed FOL change.

" Attachment 2 provides the proposed FOL change in final typed format. provides a copy of the CGS Cyber Security Plan which is a stand alone document that will be incorporated by reference into the CGS Physical Security Plan upon the staff's approval. Enclosure 3 provides a copy of the CGS Cyber Security Plan Implementation Schedule and describes commitments made in this submittal. Energy Northwest requests that Enclosure 2 and Enclosure 3, which contain security sensitive information, be withheld from public disclosure in accordance with 10 CFR 2.390. provides a table which lists the CGS Cyber Security Plan deviations from the Reference 3 template.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington State Official.

If you should have any questions regarding this submittal, please contact Mr. DW Gregoire at (509) 377-8616.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, DK Atkinson Vice President, Operational Support

Enclosures:

1) Evaluation of Proposed Change

2) Cyber Security Plan for Columbia Generating Station (Security-Related Information - Withhold Under 10 CFR 2.390)

3) Columbia Generating Station Cyber Security Plan Implementation Schedule (Security-Related Information - Withhold Under 10 CFR 2.390)

4) Columbia Generating Station Deviations from NEI 08-09, Revision 6 cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn EFSEC Manager RR Cowley - WDOH

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 1 of 7 Evaluation of Proposed Change

Subject:

Request for Approval of the Columbia Generating Station Cyber Security Plan 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

6.0 REFERENCES

ATTACHMENTS - Marked-up Page Showing the Proposed FOL Change

.Attachment 2 - Proposed FOL Change in Final Typed Format

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Enclosure 1 Page 2 of 7 1.0

SUMMARY

DESCRIPTION The proposed license amendment request (LAR) includes the proposed Columbia Generating Station (CGS) Cyber Security Plan, an Implementation Schedule, and a proposed revision to the existing Facility Operating License (FOL) Physical Protection license condition.

2.0 DETAILED DESCRIPTION The proposed LAR includes four parts: 1) the proposed Plan, 2) an Implementation Schedule, 3) a table listing deviations from Nuclear Energy Institute (NEI) 08-09, Revision 6 (Reference 3), and 4) a proposed revision to the existing FOL Physical Protection license condition 2.E to require Energy Northwest to fully implement and maintain in effect all provisions of the Commission approved CGS Cyber Security Plan as required by Section §73.54 of Title 10 of the Code of Federal Regulations (10 CFR).

The regulations in 10 CFR 73.54, "Protection of digital computer and communication systems and networks," (Rule) establish the requirements for a cyber security program.

This regulation specifically requires each licensee currently licensed to operate a nuclear power plant under Part 50 of this chapter to submit a cyber security plan that satisfies the requirements of the Rule. Each submittal must include a proposed

'implementation schedule and implementation of the licensee's cyber security program

',must be consistent with the approved schedule. The background for this application is addressed by the NRC final rule change published on March 27, 2009 (Reference 1).

3.0 TECHNICAL EVALUATION

Cyber security requirements are codified as new §73.54 and are designed to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks up to and including the design basis threat established by §73.1 (a)(1)(v). These requirements are substantial improvements upon the requirements imposed by EA-02-026 (Reference 2).

The LAR includes the proposed Plan (Enclosure 2) that conforms to the template provided in Appendix A of NEI 08-09, Revision 6 and a table listing deviations from the template (Enclosure 4). In addition, the LAR includes the proposed revision to the existing FOL license condition for "Physical Protection" (Attachments 1 and 2). Finally, the LAR contains the proposed Implementation Schedule (Enclosure 3) as required by 10 CFR 73.54.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The LAR is submitted pursuant to 10 CFR 73.54 which requires licensees currently licensed to operate a nuclear power plant under 10 CFR Part 50 to submit a Cyber Security Plan as specified in §50.4 and §50.90.

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 3 of 7 4.2 Significant Hazards Consideration Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment incorporates a new requirement in the FOL to implement and maintain a Cyber Security Plan as part of Energy Northwest's overall program for physical protection of CGS. Inclusion of the CGS Cyber Security Plan in the FOL itself does not involve any modifications to any safety-related structures, systems or components (SSCs). Rather, the CGS Cyber Security Plan describes how the requirements of 10 CFR 73.54 are to be implemented to identify, evaluate, and mitigate cyber attacks up to and including the design basis cyber attack threat, thereby achieving high assurance that CGS's digital computer and communications systems and networks are protected from cyber attacks. The CGS Cyber Security Plan will not alter previously evaluated Final Safety Analysis Report (FSAR) design basis accident analysis assumptions, add any accident initiators, or affect the function of the plant safety-related SSCs as to how they are operated, maintained, modified, tested, or inspected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?

Response: No.

The proposed amendment provides assurance that safety-related SSCs are protected from cyber attacks. Implementation of 10 CFR 73.54 and the inclusion of a plan in the FOL do not result in the need for any new or different FSAR design basis accident analysis. It does not introduce new equipment that could create a new or different kind of accident, and no new equipment failure modes are created. As a result, no new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of this proposed amendment.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 4 of 7

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The margin of safety is associated with the confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant pressure boundary, and containment structure) to limit the level of radiation to the public. The proposed amendment would not alter the way any safety-related SSC functions and would not alter the way the plant is operated. The amendment provides assurance that safety-related SSCs are protected from cyber attacks. The proposed amendment would not introduce any new uncertainties or change any existing uncertainties associated with any safety limit. The proposed amendment would have no impact on the structural integrity of the fuel cladding, reactor coolant pressure boundary, or containment structure. Based on the above considerations, the proposed amendment would not degrade the confidence in the ability of the fission product barriers to limit the level of radiation to the public.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Energy Northwest concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusion Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the applicable regulations as identified herein, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment establishes the licensing basis for a Cyber Security Program for CGS and will be a part of the Physical Security Plan. The proposed amendment would not change any requirements with respect to installation or use of a facility component located within CGS's restricted area, as defined in 10 CFR 20.1003.

Accordingly, the proposed amendment does not involve: (1) a significant hazards consideration, (2) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposure. The proposed amendment meets the criteria for categorical exclusion in accordance with 10 CFR 51.22(c) and no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 5 of 7

6.0 REFERENCES

1. Federal Register Notice, Final Rule 10 CFR Part 73, Power Reactor Security Requirements, published on March 27, 2009, 74 FR 13926

2. EA-02-026, Order Modifying Licenses, Safeguards and Security Plan Requirements, issued February 25, 2002

3. NEI 08-09 Revision 6, "Cyber Security Plan for Nuclear Power Reactors,"

April 28, 2010

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 6 of 7 Attachment 1 - Marked-up Page Showing the Proposed FOL Change 10-Dbý.EýXqmipti,ýons from certai r1nrequi rements ofl Ap'pen~di.cqs, 0l, H and J Pa t50, are descri`bed in the Safety Eval ion 'Rdprt. These toiexemptions 10 CER

,are authorized by law: and will not endanger liife or property or the 'common

,defenris.e ,arnd security and a~re othe~rwi:se in. th:.e public ifntere~st1.. Th;ef or e.,

thpese exmptions ar, he* *eb' granted pur;Suant tob 10' C.FR 50,12. With the

.gran ti'ng of this :exempt.ion the, facili"y will operate to the ext.ent aut.horized, herein in conformity, wi'th the arplicaton as am'.ded te prOisinsO of the Act', an.'d the rules -ndo r.qu~ions of teq Comiil n.

E,ý The l1icensee shaoll fully inip'lement and imain-ain in effect all pirovisions of tIhe CGommisionapproved hys*cal securuty: plan, Lra~i ning anod ua ificati'on

, I on, ngency p1 en, intl di nqý anrdeits pl0n anr ,d ,ýafroguaii1ý ade pur ýýuarit to, provi si.ons: of the Mi sce1*.aneous Amendments add, Search Requ rements revi sions 1or1 0 R! 73 .55 (\1 FR.*27817 and 21822) and -o toe auihority of 10" CFR 50Q.90 aridt 10 CFR 5095 p) .he. pl.IIan woiich c)rtri jns, Safegu ards Tn formationi prottected under 10.CFR 73 .21 is entit1led::. *.Cbl uinbi a Genera,'ting Station Pys:ical' Secity: an -irainingý and Qualification Plan,

'Safeguards #contingency Plan .. ariO d ndepende;rit ,Spoent; Fuel Sto:rage Insitallati~ion P1a:n, Rpevision 3 ."ub it ted. May 18, 2006..

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it rhann one hour_ of. ary at cl der t a'_ Ihi f -i Ic- iA'y wh.ich could reisult 1r an:

unplaýnned release o'f quantities oF Fission. pyioduots, in excedss, of allowo.ble 1 imi ts fori norma,] ope o n.".ý,r

ýestabl i,:shed t)y4yt C;i iisiiidni.

1 tH", the ic.s.e* shall have.ad ma,~intafn f rancdjaT :protpect'i~on of sicph type: and in s'uch aambuntf as the Commiissi dn sha' requ'ii in accor adne* With e.1/2tcio n 1,70 of the.,Atomic Ene.rgy 'Act of 1954,. as amended, to cover public 'li ab.l]i',ti>y

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Strike out .206" Amendmrent No. 2_-8--&

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REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 7 of 7 Attachment 2 - Proposed FOL Change in Final Typed Format U. Exemptions from certain requirements of Appendice.s , H and J teo IOCFR Part 50,,. are described in thle.Safety' Evaluation Report. These exemptions are authorized by law and will not.-endanger life or property or the common defense 'and security and areotherwiseih :the public interest. Therefore, thesel exemptions are 'her.eby granted pursuant .to 10 CQFR 50.12. W the granting of this exemption the faility will 'peorate, to the extent authorized hereein, in conformity with thei application, as amended, the provisions ýof the Act, -and the rules: and regulations ofIthe ýCommission.

E.. The licensee shall fully implemenrt an~d mai ntain in effect all provisions., of the C6ornmission-'approved Colurnbia Generating Station cyber security plan, physical security plan, training and qualificatioh plan, and safeguards contingency plan, including amendments! made pursuant io provisions otfthe Mi scel.laneo.us-Amendments 'and Search Requirements revi~sioins to '10 C.FR 73.55 (51 FR 27817 .and 278.22) and to the autho.rity of 10 CFR. 50.90 and 101CFR 50.54(p)., The plan, :whic co ntains Safeguairds Information protected under 10 CFR 73.21, is.entitled: ",Cblumbia Generating Station Physical. Security Plan, Training and. Qualification Plan, Safeguards Contingency Plan, and Independe.nt Spent Fuel StoGrage Installation Plan, Revision 3T submitted May 1.8 , 2006,.

F. Deleted.,

-G, The licensee shall notify the Commission, as* soon as possible but not.later than one. hour-, of any accident :atthi s, facil!.ty whichco.ould result inan.

unplanned release of quantities :of fissionr products in excess, of allowable limits for normal operation established by the Commission.

H. Thel licenseeý shall have and maintain financial protection :of such type and. in, such-amouints as the Commissioni. shall .require in a'ccordance with Section 170 of the Atomic Energy Act of 1:954, as-amended,1 to cover public liabi/ity claims'.

.Amendment No. :7,178, **3, 20*

flcvizzd by lettcr dated FobruarY 2, 2007

REQUEST FOR APPROVAL OF THE COLUMBIA GENERATING STATION CYBER SECURITY PLAN Page 1 of 1 Columbia Generating Station Deviations from NEI 08-09, Revision 6 NEI 08-09 NEI 08-09 Wording CGS Deviation Location Appendix A, [Site/Licensee] Energy Northwest acknowledges that the Section 1 acknowledges that the implementation of this plan does not alleviate 1st Paragraph implementation of this plan responsibility to comply with other NRC does not alleviate their regulations. Deleted the word "their" for responsibility to comply with grammatical correctness.

other NRC regulations.

Appendix A, A Glossary of terms used This wording has been replaced with the Section 1 within this Plan and actual terms contained within NEI 08-09, 3 rd Paragraph Appendices of NEI 08-09, Revision 6, Appendix B. CGS has elected to Revision 6, is contained in incorporate the definitions directly into the Appendix B of NEI 08-09, Cyber Security Plan.

Revision 6.

Section 3.1.3 - Refer to NEI 08-09, Revision Refer to Section 1.3 for definition of Critical 1 st Bullet 6, Appendix B, Glossary for System. Maintains consistency of definition of Critical System. incorporating definitions directly.

Section 3.1.3 - Refer to NEI 08-09, Revision Refer to Section 1.2 for definition of Critical 2 nd Bullet 6, Appendix B, Glossary for Digital Asset. Maintains consistency of definition of Critical System. incorporating definitions directly.

Appendix B, Any event in which there is This term has been added as Section 1.4 in "Cyber Attack" reason to believe that an the plan and the wording has been changed adversary has committed or to read:

caused, or attempted to commit or cause, or has Any event in which there is reason to believe made a credible threat to that an adversary has committed or caused, commit or cause malicious or attempted to commit or cause, or has exploitation of a SSEP made a credible threat to commit or cause function. malicious exploitation of a CDA.

Reference 1 below concluded that submission of the cyber security plan in accordance with NEI 08-09, Revision 6 with the exception ofttheh_definition of "cyber attack" would be acceptable. Reference 2 provided the above wording as an acceptable definition of "cyber attack" which has been incorporated as Section 1.4 in this plan.

References:

1) NRC Letter dated May 24, 2010, CF Lyon (NRC) to JV Parrish (Energy Northwest), "Columbia Generating Station - License Amendment Request for Approval of the Cyber Security Plan (TAC No. ME2624)"

2) NRC Letter dated June 7, 2010, RP Correia (NRC) to CE Earls (NEI), "Nuclear Energy Institute 08-09, 'Cyber Security Plan Template, Rev. 6"'